HomeMy WebLinkAboutAQ_F_0200072_20220126_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hancock&Moore,LLC dba Hancock&Moore
Plant 3
Inspection Report NC Facility ID 0200072
Date: 01/26/2022 County/FIPS: Alexander/003
Facility Data Permit Data
Hancock&Moore,LLC dba Hancock&Moore Plant 3 Permit 07535/R08
405 Rink Dam Road Issued 9/19/2017
Hickory,NC 28601 Expires 8/31/2025
Lat: 35d 48.9300m Long: 8ld 18.1056m Class/Status Small
SIC: 2512/Upholstered Household Furniture Permit Status Active
NAICS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robert Hatfield Bryan Craft Dennis Tart
Maintenance Supervisor Plant Manager Environmental Engineer
(828)578-2867 (828)326-8376
Compliance Data
Comments:
Inspection Date 01/26/2022
7- Inspector's Name Karyn Kurek
Inspector's Signature: XafyrvK,Iwek/ j9JX Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 1/27/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 15.13 --- 0.1000 3.24 0.0800 8.44 476.67
2011 12.87 --- 0.1100 11.60 0.0900 7.99 1465.92
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 26,2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 1/27/2022 IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked IBEAM Complaint
_X IBEAM Planning,Next Inspection Date 1/1/2024
Directions: From MRO,travel I-77 north to 1-40 west. Take Hwy. 16 exit and travel north on Hwy. 16
toward Taylorsville. Travel approximately 9 miles and turn left onto Friendship Church Road. Travel
approximately 2 miles and turn left onto Church Road. Travel approximately 1 mile and turn right onto
Rink Dam Road. Travel approximately 4 miles and the facility will be located on the right at 405 Rink
Dam Road.
Safety Equipment: Safety glasses, safety shoes and ear protection are recommended.
Safety Issues: None noted.
Lat/Long Coordinates: A review of the facility's coordinates on DAQ's"Facilities Regulated by Air
Quality"website indicates the facility latitude and longitude coordinates are not listed,however the
location appears to be accurate.No changes to the latitude and longitude coordinates of this facility in
IBEAM are needed.
Email Contacts: IBEAM email contacts were reviewed and updated.
Covid: Masks are required regardless of vaccination status.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures upholstered furniture. The facility is currently operating forty hours per week, 50
weeks per year with approximately 125 employees. I arrived at the facility on January 26,2022.
Mr. Dennis Tart,Environmental Engineer, accompanied me during this inspection.
2. Facility Contact Information:
IBEAM email contacts were reviewed and updated.
3. Compliance history file review:
No problems have been noted in the last five years by DAQ,prior to this inspection. The current
compliance status is discussed in the following sections.
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 26,2022
Page 3
4. Observations of permitted air emission sources and control devices:
Emission FEmission Source Control Control System
Source ID Description System ID Description
SB-1, SB-2, SB-3 three (3)dry-filter type paint spray
booths installed on a furniture spray N/A N/A
painting operation
Observed.None of the spray booths were observed in operation at the time of inspection.
The booths are equipped with air flow sensors(cfm),which will shut off the booth fan if
there is not adequate air flow through the filters. All booths utilize HVLP spray guns. All
filters were in place and appeared to be in good operating condition.
Emission Emission Source Control Control System
Source Description System ID Description
ID
ES-1 woodworking C-2, C-1 One (1) simple cyclone(ID No. C-1, 12
equipment feet in diameter)installed in series with
one (1) simple cyclone(ID No. C-2, 8.5
feet in diameter)
H-1 wood hog C-1 One (1) simple cyclone(ID No. C-1, 12
feet in diameter)
Observed.During the last inspection,the facility had installed a new CNC wood cutting
machine and planned to install a second unit; the second CNC unit has been installed.
Both CNC units were observed in operation with no issues noted. These units are vented
through the cyclones.All the woodworking equipment is vented to cyclone C-1. The
collected wood waste is transferred to a storage bin via cyclone C-2. The wood hog(ID
No. H-1) also vents to cyclone C-2. The facility processes approximately 3500 bd. ft. of
lumber per month. The cyclone is emptied via truck approximately every two weeks. The
woodworking equipment(ES-1),wood hog(H-1), and cyclones (C-1 &C-2)were
observed in operation with no visible emissions or buildup of sawdust around any exhaust
points.
5. Observations of insignificant air emission sources and control devices listed on the current
permit:
Exemption Source of Source of
. Source M
Regulation TAPs? Title V
Pollutants.
IB-01 -natural gas/No. 2 fuel oil-fired
boiler only firing fuel oil during periods 2Q .0102 (g)(5)(A) Yes Yes
of natural gas curtailment(4.18 million
Btu per hour maximum heat input)
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 26,2022
Page 4
Observed.The boiler(Trane— 1973)is used for comfort heat and was in operation at the
time of this inspection.
Exemption Source of Source of
Source Regulation TAPs? Title V
Pollutants?
I-Wash-washoff tank 2Q .0102 (h)(5) No No
Observed. The tank was not observed at the time of inspection.
Exemption Source of Source of
Source Regulation I TAPs? Title V
Pollutants?
I-Bleach-bleach booth 2Q .0102 (h)(5) No I No
Observed. The booth was not observed at the time of inspection. The booth is no longer
used.
6. Observations of air emission sources and control devices not listed on the current permit:
a. N/A
7. Compliance with specific permit conditions and limitations:
a. Condition A.2. 15A NCAC 2Q .0304(d) and(f) "Permit Renewal and Emission
Inventory". The Permittee, at least 90 days prior to the expiration date of this permit,
shall request permit renewal by letter.
Observed. Permit 07535R08 was issued September 19,2017 and does not expire until
August 31,2025.No action is required at this time. Compliance with this stipulation is
indicated.
b. Condition A.3. 15A NCAC 2D .0512 "Particulates From Wood Products Finishing
Plants". Provide adequate ductwork and properly designed collectors to control
woodworking particulates.
Observed. The spray booths were properly maintained with no issues noted.Wood
particulate appeared to be properly controlled. No sawdust waste was observed at
exhaust points around the cyclones and ductwork appears to be properly maintained.
Compliance with this stipulation is indicated.
C. Condition A.4. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is
limited to 20 percent opacity.
Observed. No visible emissions were observed at the facility during inspection.
Compliance with this stipulation is indicated.
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 26,2022
Page 5
d. Condition A.5. 15A NCAC 2D .0535. Permittee of a source of excess emissions that last
for more than four hours and that results from a malfunction, a breakdown of process or
control equipment or any other abnormal conditions, shall notify the Director or his
designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business
day of becoming aware of the occurrence.
Observed. Based on a records review and conversation with Mr. Tart,no excess
emissions have occurred at the facility. Compliance with this stipulation is indicated.
e. Condition A.6. 15A NCAC 2D .0540"Particulates from Fugitive Dust Emission
Sources." The Permittee shall not cause or allow fugitive dust emissions to cause or
contribute to substantive complaints or excess visible emissions beyond the property
boundary.
Observed. There have been no complaints received by the MRO regarding the facility
and no fugitive dust emissions were observed at the time of this inspection. Compliance
with this stipulation is indicated.
f. Condition A.7. CYCLONE REQUIREMENTS. Conduct an annual inspection of the
cyclone systems. Perform inspections and maintenance as recommended by the
equipment manufacturer and list corrections made and dates of actions in a cyclone
logbook.
Observed. The facility had been conducting monthly inspections of the wood waste
collection system until staff reductions at which time they are conducting them annually.
The facility maintains records of these inspections. The most recent inspections were
conducted on January 22,2020,February 20,2020,March 11,2020,April 23,2020,
October 8,2020, and September 30,2021. Compliance with this stipulation is indicated.
g. Condition A.8. 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions"
the Permittee shall not operate the facility without implementing management practices
or installing and operating odor control equipment sufficient to prevent odorous
emissions from the facility from causing or contributing to objectionable odors beyond
the facility's boundary.
Observed. No odors were detected inside or outside the plant during the time of
inspection. Compliance with this stipulation is indicated.
h. Condition A.9. "Avoidance of NESHAP 40 CFR 63 Subpart 6J"-The Permittee is
subject to this subpart if they own or operate an industrial,commercial,or institutional
boiler that is located at, or is part of, an area source of hazardous air pollutants(HAP).
The Permittee has agreed to only burn fuel oil during periods of natural gas curtailment
or maintenance to avoid being subject to this requirement.
Observed.The boiler(Insignificant ID No. I13-01;natural gas/No. 2 fuel-oil fired,4.18
MMBtu/hr)is subject to the Subpart 6J Boiler MACT. In order to avoid being subject to
NESHAP Subpart JJJJJJ the facility has agreed to only burn fuel oil during periods of
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 26,2022
Page 6
natural gas curtailment or maintenance. The facility must keep records of fuel oil burned
and the reason for burning it.
Observed. The facility has only used natural gas,no fuel oil has been used for
curtailment. Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review
a. The facility was sent a letter on November 13,2007 regarding Subpart 000000
"Flexible Polyurethane Foam Manufacturing." The facility does not conduct any type of
foam manufacturing or fabrication and therefore is not subject to the referenced subpart.
b. The boiler(Insignificant ID No. IB-01;natural gas/No. 2 fuel-oil fired,4.18 MMBtu/hr)
is subject to the Subpart 6J Boiler MACT. In order to avoid being subject to NESHAP
Subpart JJJJJJ,the facility has agreed to only burn fuel oil during periods of natural gas
curtailment or maintenance. The facility must keep records of fuel oil burned and the
reason for burning it. The facility has only used natural gas,no fuel oil has been used for
curtailment. Therefore,this facility appears to be in compliance.
c. There are no emergency generators and the fire pump onsite is electric,therefore the facility
is not subject to NESHAP 4Z.
d. The facility does not have any gasoline storage tanks onsite,therefore,it is not subject to
NESHAP 6C.
9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered duringtpection:
None.
11. Section 112(r) apTlicability:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r)of the Clean Air Act.
12. Compliance determination:
Based on my observations,this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
KAK:lms
cc:MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00072/INSPECT 20220126.doc